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7/30/2019 HSEQ Manual http://slidepdf.com/reader/full/hseq-manual 1/34 EMAS  EMAS OFFSHORE CONSTRUCTION AND PRODUCTION PTE LTD Title Procedure No. Rev. Health, Safety, Environmental and Quality Management System Manual MAN – EOCP – CORP - HSEQ - 501 0 1 | 34  Health, Safety, Environmental and Quality Management System Manual MAN-EOCP-CORP-HSEQ-501 Revision List 0 15 Mar 2007 Issue for Implementation ZG FI KKL  A2 13 Feb 2007 Issue After Comments ZG FI KKL  A1 28 Dec 2006 Issue For Review ZG FI KKL Revision Date Reason for Issue Prepared by Checked by  Approved by HSEQ  Approved by - Printed copies are uncontrolled. For current controlled copies, please contact EOCP HSEQ Dept.-

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7/30/2019 HSEQ Manual

http://slidepdf.com/reader/full/hseq-manual 1/34

EMAS 

EMAS OFFSHORE CONSTRUCTIONAND PRODUCTION PTE LTD 

Title Procedure No. Rev.

Health, Safety, Environmental and Quality Management System Manual MAN – EOCP – CORP - HSEQ - 501 0

1 | 34  

Health, Safety, Environmental and Quality

Management System Manual

MAN-EOCP-CORP-HSEQ-501

Revision List

0 15 Mar 2007 Issue for Implementation ZG FI KKL

 A2 13 Feb 2007 Issue After Comments ZG FI KKL

 A1 28 Dec 2006 Issue For Review ZG FI KKL

Revision Date Reason for Issue Prepared by Checked by Approved

byHSEQ

 Approved by

- Printed copies are uncontrolled. For current controlled copies, please contact EOCP HSEQ Dept.-

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EMAS 

EMAS OFFSHORE CONSTRUCTIONAND PRODUCTION PTE LTD 

Title Procedure No. Rev.

Health, Safety, Environmental and Quality Management System Manual MAN – EOCP – CORP - HSEQ - 501 0

2 | 34  

Table of Contents

1.  INTRODUCTION ............................................................................................................................ 5 1.1  Overview........................................................................................................................................................................... 5 1.2  Purpose ............................................................................................................................................................................ 5 1.3  Scope ............................................................................................................................................................................... 6 1.4  References ....................................................................................................................................................................... 6 

2.  LEADERSHIP AND COMMITMENT .............................................................................................. 7 

3.  POLICY AND STRATEGIC OBJECTIVES .................................................................................... 7 3.1  HSEQ Policy ..................................................................................................................................................................... 7 3.2  Business Objective ........................................................................................................................................................... 9 3.3  HSEQ Strategic Objective ................................................................................................................................................ 9 3.4  Key Performance Indicators (KPI) .................................................................................................................................... 9 3.5  Legal Requirements ......................................................................................................................................................... 9 3.6  Client’s HSEQ Requirements ........................................................................................................................................... 9 

4.  ORGANIZATION, RESPONSIBILITIES AND RESOURCES ...................................................... 10 4.1  Organisation and Responsibilities .................................................................................................................................. 10 4.2  Resources, Training and Competence ........................................................................................................................... 10 4.3  Communication............................................................................................................................................................... 11 4.4  Customer Communication .............................................................................................................................................. 11 

5.  HAZARDS AND EFFECTS MANAGEMENT ............................................................................... 12 5.1  Hazards and Effects Identification .................................................................................................................................. 12 5.2  Risk Assessment ............................................................................................................................................................ 12 5.3  Control and Recover....................................................................................................................................................... 13 

6.  PLANNING AND PROCEDURES ................................................................................................ 15 6.1  HSEQ and Emergency Planning .................................................................................................................................... 15 6.2  Document Control........................................................................................................................................................... 16 6.3  Operation Control Procedures ........................................................................................................................................ 21 

7.  IMPLEMENTATION AND MONITORING .................................................................................... 26 7.1  Responsibility and Ownership ........................................................................................................................................ 26 7.2  Performance Indicators and Measurement .................................................................................................................... 27 7.3  Monitoring Program ........................................................................................................................................................ 27 7.4  Data Accuracy and Calibration ....................................................................................................................................... 27 7.5  Records .......................................................................................................................................................................... 27 7.6  Incident Investigation and Reporting .............................................................................................................................. 28 7.7  Corrective and Preventive Action ................................................................................................................................... 28 7.8  Non-Conformance .......................................................................................................................................................... 29 

8  AUDIT ........................................................................................................................................... 30 8.1   Audit Plan, Process and Hierarchy ................... ...................... ...................... ...................... ..................... ...................... 30 8.2   Audit Team and Frequency ....................................... ...................... ..................... ...................... ...................... .............. 32 

9  REVIEW ........................................................................................................................................ 33 9.1  Scope of Review............................................................................................................................................................. 33 9.2  Responsibility for Review ............................................................................................................................................... 33 

ATTACHMENTS ................................................................................................................................... 34 

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Definitions and Abbreviations

Accident Undesired event giving rise to death, ill health, injury, damage or other loss.

ALARP  As Low As Reasonably Practicable

ASV  Accommodation Service Vessel

CAR Corrective and Preventive Action Request

CMT Crisis Management Team

Corrective Action  Any activity undertaken to address an incident or non compliance and if 

possible, prevent its recurrence.

Contingency Plan  A pre-established plan to mitigate an unusual situation which has the potentialfor harm, which incorporates the best use of local as well as remote facilitiesand resources.

ContinuousImprovement

Year-on-year enhancement of overall health, safety and environmentalperformance, not necessarily in all areas of activity, resulting from continuousefforts to improve.

Damage toEnvironment

 A direct or indirect adverse impingement of the activities, products or services of the company upon the environment.

Defect Non-fulfillment of a requirement or specification related to an intended or specified use.

Effect The severity of the consequences of an event attributed to any hazards,normally expressed in terms of consequences to people, environment, assetand reputation.

EC Emergency Coordinator 

EOCP Emas Offshore Construction and Production Pte. Ltd.

ERP Emergency Response Plan

ERT Emergency Response Team

FPSO Floating, Production, Storage and Offloading

Hazard The potential to cause harm, including ill health or injury, damage to property,plant, products or the environment; production losses or increased liabilities.

HAZID Hazard Identification

HAZOP Hazards and Operability Study

HEMP Hazard and Effects Management Process

HSEQ Health, Safety, Environment and Quality

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HSEQ Audit Independent, systematic and documented process of objectively obtaining andevaluating verifiable evidence to determine that HSEQ-MS is effectively

implemented.

HSEQ Inspection Physical on-Project verification that work is performed and equipment ismaintained in accordance with existing HSEQ standards and procedures.

HSEQManagementReview

Periodic review of HSEQ performance and effectiveness of HSEQ-MS bymeans of documented performance data. HSEQ review is conducted at multipleorganization levels in varying level of detail.

ILO International Labour Organization

Incident Event that gave rise to an accident or had the potential to lead to an accident.

ISM International Safety Management

JSA Job Safety Analysis

KPI Key Performance Indicator 

Lock-out Tag-out  A documented system of physical barriers and notices that prevents theaccidental or inadvertent operation of equipment whilst it is being maintained or inspected.

LTI Loss Time Incident

Near Miss  An incident or potential incident which resulted in no actual harm to people, theenvironment, facilities or business.

NGO Non-government Organization

Non-conformance Failure to meet the HSEQ-MS requirements. Non-conformance may beidentified by monitoring activities, adverse trends in performance indicators,non-completion of HSEQ plans, non-compliance to legal and other requirements, failure to meet targets, incident investigations and audits.

OHSAS Occupational Health and Safety Assessment Series

PD Permanent Disability

PPE Personal Protective Equipment

PQP Project Quality Plan

PTW Permit-to-Work

SIMOPS Simultaneous Operations

SMM Safety Management Manual Emas Offshore Vessels

TBM Tool Box Meeting

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1. INTRODUCTION1.1 OverviewThe management of EOCP profess to unequivocal commitment in providing a safe work place,respect for the environment and the highest standards of operational professionalism.

The EOCP HSEQ manual describes the process for managing EOCP’s Health, Safety, Envir onmentand Quality Management System (HSEQ-MS) at the corporate level and within any project or operational units.

The HSEQ-MS is an integrated management tool that describes the EOCP organization,responsibilities, processes, practices, procedures and resources for implementing the company’sHSEQ policies.

The model used to represent EOCP HSEQ-MS is based on the ISO 9001/ OSHAS 18001 principlesas shown in Figure 1.1 below.

Figure 1.1: EOCP HSEQ-MS Model

1.2 PurposeEOCP HSEQ-MS defines the Company’s HSEQ Policy, Guiding Principles, Strategic Objectives,organization and the arrangements which are necessary to manage the identified health, safety,environmental and quality risks associated with EOCP businesses.

The purpose of this HSEQ-MS is to ensure that:

HSEQ risks have been systematically identified;

Measures are in place to control these risks, mitigate consequences should the needs ariseand at the same time providing continual improvement in HSEQ MS;

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It provides a set of HSEQ expectations and requirements for all levels within the organisationwith a view to ensuring consistent reporting and control over operational risks;

  Company’s Policies, Procedures and Best Practices are communicated; and

Training, auditing and improvement processes are in place to achieve these objectives.

The HSEQ-MS Manual is a corporate level document intended for use by managers to assure themthat all foreseeable risks will be effectively managed throughout the organization. Managers areresponsible for the provision of necessary business controls to ensure currency of the HSEQ-MS andits effectiveness in the management of those risks.

The HSEQ-MS manual will be reviewed annually and updated accordingly. A review of this Manual willalso be triggered by any major incidents or due to any significant deficiencies found in the HSEQ-MSarising from audits or reviews of other parts of the system or Company (e.g. review of HSE Cases or ISO/ISM/Client audits). This manual is a live document and the EOCP Corporate HSEQ Department

shall be its custodian.

1.3 ScopeThe scope of this document covers the activities of EOCP Leadership Team, the Corporate Office andProject/Operational Site staff providing advice and guidance to all business operations on themanagement of their activities under their operational control.

EOCP is primarily servicing the offshore oil and gas industry (pipe-laying/heavy lift/accommodationbarges, FPSOs, shipbuilding) and its business operations, encompasses the following:

Engineering and Procurement services;

Construction;

Project Management;

Hook-up and Commissioning;

Offshore support services including Installation; and

Operations and Maintenance.

In line with EOCP HSEQ policy, implementing and complying with the HSEQ-MS is the directresponsibility of everyone in the Company within their own individual sphere of operations includingcontractors engaged by EOCP.

1.4 ReferencesThe main reference documents used in the development of this HSEQ-MS are as listed below:

E and P Forum, Guidelines for the Development and Application of Health, Safety andEnvironmental Management Systems, Report No. 6.36/210;

American Petroleum Institute, Model Environmental, Health and Safety (EHS) ManagementSystem, API Publication 9100A;

International Labour Organization, Guidelines on Occupational Safety and HealthManagement Systems, ILO-OSH 2001;

Quality Management System, ISO 9001:2000.

Environmental Management System, ISO 14001:2004; and

Safety Management Manual, Emas Offshore and Marine Services

International Safety Management (ISM) Code, 1993;

The consistency between EOCP HSEQ-MS with ISO and ISM Standards is demonstrated in Attachment A.

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2. LEADERSHIP AND COMMITMENT

EOCP Senior Management provides strong and visible  leadership to promote a culture in which allemployees share a commitment to HSEQ. They do this through setting a personal example,demonstrating commitment to implementing the HSEQ-MS, communicating HSEQ expectations withemployees, discussing and reviewing progress against specific HSEQ goals including set KeyPerformance Indicators (KPI) targets and demonstrating personal participation in HSEQ activities.

The Senior Management is proactive in target setting. They do this through developing and discussingimprovement targets, ensuring staff have HSEQ goals in their appraisals, participating in the review of HSEQ indicators, providing immediate and visible involvement in incidents and in setting Targets.EOCP seeks to create and sustain a Company culture in which all employees share a commitment to

HSEQ. Both EOCP employees and contractors are involved in creating and maintaining thissupportive culture.

The Senior Managements demonstrate an informed involvement in HSEQ issues. They do thisthrough reviewing the progress in the development and content of the HSEQ Management System,making resources available to meet set goals and undertaking relevant training. In addition, they arefully aware of the high priority areas for improving EOCP HSEQ Management System and arepersonally involved in improvements arising from formal management reviews of the HSEQManagement System.

3. POLICY AND STRATEGIC OBJECTIVES3.1 HSEQ PolicyIt is important that EOCP HSEQ Policy is initiated, developed, actively supported and endorsed bymanagement at the highest level and made available in readily understood form to interested parties.Senior Management of EOCP defines and documents its HSEQ Policy and Strategic Objectives andensures that they:

Are consistent with those of the Company’s external stakeholders;

   Are relevant to the Company’s activities, products and services;

Are consistent with and are of equal importance to EOCP other business policies andStrategic Objectives;

Are publicly available;

Commit the Company to meet or exceed all relevant regulatory and legislative requirements; Commit the Company to reduce the risks and hazards to health, safety and the environment to

levels, which are As Low As Reasonably Practicable (ALARP); and

Provide a framework to continuous efforts to improve HSEQ performance.

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3.2 Business ObjectiveEOCP establishes Annual Business Objectives which includes Quality, Health, Safety andEnvironment Objectives for all its business units. EOCP is committed to meeting these expectations inall its business activities. These are further enhanced by HSEQ Strategic Objective.

3.3 HSEQ Strategic ObjectiveEOCP HSEQ Strategic Objectives are captured in the annual Corporate HSEQ Plan and reappraisedin Project HSEQ Plans with actual performance and changing expectations of the variety of stakeholders. The HSE and QA Department is responsible to advise Managing Director and the EOCPManagement Team on the appropriate strategic objectives required to improve HSEQ based onprevailing HSEQ performance data, HSEQ-MS reviews, audit findings and safety studies.

3.4 Key Performance Indicators (KPI)Various measurements are used in EOCP projects to monitor, understand, predict and improveperformance outcomes to meet our Business Objectives. Performance is demonstrated by achievingthe KPI.

Please refer to Section 7.2.1 Performance Indicators and Measurements.

3.5 Legal RequirementsIn conducting its business as a good and responsible corporate citizen, EOCP complies with the

principles embedded in the local legislations and international conventions.

EOCP HSEQ-MS describes the processes for identifying the legal HSEQ requirements that areapplicable to EOCP activities, products and services and for incorporating these legal requirementsinto EOCP HSEQ policies, strategic objectives and the HSEQ-MS generally.

EOCP maintains procedures to determine and record legislative requirements and codes applicable toits operations, products and services to ensure compliance with such requirements.

Legal and Other Requirements Identification Procedure (BP-EOCP-CORP-HSE-506)

3.6 Client’s HSEQ Requirements Client representatives assigned to EOCP are consulted in order to ensure that their HSEQexpectations and EOCP HSEQ-MS requirements are complimentary, consistent and workablethroughout the operation/project phases.

EOCP initiates, on a proactive basis, a bridging session in order to address any interface betweenEOCP and Client’s HSEQ requirement. The agreed interface solutions are in place before anyfieldwork is initiated.

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4. ORGANIZATION, RESPONSIBILITIES AND RESOURCES4.1 Organisation and ResponsibilitiesThe EOCP business unit interface with support services is described below in Figure 4.1:

Figure 4.1: EOCP Unit Business Interface

The EOCP business unit is supported by common support services. These services include Accounting, Project Controls, HSE, Quality, Information Technology , Communications, and HumanResource provides support to both the Sales and Business Execution Processes. The EOCPOrganization Chart is illustrated in Attachment B.

Specific HSEQ roles and responsibilities of the EOCP Senior Management and other companypersonnel including contractors are detailed in Attachment C.

4.2 Resources, Training and CompetenceEffective operation of EOCP HSEQ-MS requires sufficient allocation of human, physical and financialresources. Resource requirements are considered during the HSEQ planning and review processes.Resource allocations are considered when managing change and during assessment of controls aspart of the Hazards and Effects Management Process (HEMP).

Effective allocation of physical resources including facilities requires consideration of the HSEQ risksthat arise in all EOCP activities, including the supply chain.

Human resources  include both EOCP staff and contractors. Effective HSEQ management relies onthe competence of these people.

Business Development 

&Acquisition 

Engineering &

Procurement 

Construction &

Construction Management 

Installation Hook  –up Commissioning 

EOCPPROJECT MANAGEMENT

AACCCCOOUUNNTTIINNGG 

HHUUMMAANN RREESSOOUURRCCEE 

IINNFFOORRMMAATTIIOONN TTEECCHHNNOOLLOOGGYY 

QQUUAALLIITTYY HHEEAALLTTHH,, SSAAFFEETTYY && EENNVVIIRROONNMMEENNTT DDOOCCUUMMEENNTT CCOONNTTRROOLL 

PPRROOJJEECCTT CCOONNTTRROOLL CCOOMMMMUUNNIICCAATTIIOONNSS 

SSUUPPPPOORRTT SSEERRVVIICCEESS 

B B U U S S I I N N E E S S S S E E X X E E C C U U T T I I O O N N  

CC UU SS TT 

OO MM EE RR 

CC UU SS TT 

OO MM EE RR 

Operations &

Maintenance 

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EOCP maintains a procedure to ensure competence by identifying training needs and providingappropriate training for all staff and contractors. Training is provided through formal courses or through

structured programs in the workplace (on the job training). The extent and nature of training ensuresachievement of EOCP HSEQ policies and objectives. The training programs also meet or exceedstandards set by legislations and clients. Appropriate records of training are maintained withsubsequent refresher training scheduled on periodic basis. All EOCP contractors also are subjected tothis requirement.

Competency assessment process applies to initial recruitment and also to selection of personnel for new tasks. The competency of staff and contractors to perform their duties is regularly reviewed andevaluated, including appropriate consideration of training required to achieve desired competencylevel for changing tasks, processes and equipment.

 Any lapses of competency identified are addressed with appropriate formal or workplace trainingconducted by their respective supervision.

HSE Training and Competence Evaluation Procedure (WP-EOCP-CORP-HSE-507)

4.3 CommunicationHSEQ issues are communicated to employees, contractors, partners and other interested parties tomake them aware of:

Roles and responsibilities in achieving compliance with defined HSEQ policies and objectives;

Hazards and risks related to their work activities focusing on identification, evaluation, controland recovery measures;

Assessed and approved deviations from agreed and documented operating procedures; and

Incidents and lessons learnt to avoid repetition in other locations or areas of the business.

EOCP provides the following channels for effective communication :

EOCP Website including HSEQ-MS Portal

EOCP Induction for New Hires/Visitors

HSEQ Steering Committee

Department/Project/Contractor Safety Meetings

Daily Tool Box Meetings

Safety Alerts, Safety Posters and HSEQ Statistics Displays

Internal and External Communication Procedure (WP-EOCP-CORP-HSE-508)

4.4 Customer CommunicationEOCP determines and implements effective arrangements for communicating with customers inrelation to:

Product information which includes whole range of services offered by EOCP;

Enquiries, contracts or order handling, including amendments; and

Customer feedback, including customer complaints.

Customer Satisfaction Procedure (PM-EOCP-CORP-QMS-504)Customer Feedback Procedure (PM-EOCP-CORP-QMS-539)

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5. HAZARDS AND EFFECTS MANAGEMENTThe identification, assessment and management of hazards are a vital element of a successful HSEQ-MS. The Hazard and Effects Management Process (HEMP) is the tool used for this. The HEMP shouldfirst be applied to high level corporate activities and then to all HSEQ critical company activities at thelower, more detailed level, through the respective project assessments and safety case studies.

The HSEQ-MS provides a structured, documented management system that seeks to ensure that allforeseeable hazards have been identified, risks assessed and the necessary control/recoverymechanisms and procedures have been clearly defined. The HEMP of identify-assess-control-recover provides the basis for the identification of deficiencies from which a prioritized Remedial Action Planfor correction or improvement can be developed.

 All HSEQ risks that arise out of and in the course of EOCP activities, including contractor activities are

reduced to a level that is as low as reasonably practicable (ALARP).

EOCP Management Team provides the required support and resources, to enable the implementationof the required risk management activities.

Hazard and Effect Management Procedure (PM-EOCP-CORP-HSE-509)

5.1 Hazards and Effects IdentificationEOCP maintains procedures to identify systematically and record the hazards and effects which mayarise from its activities. The hazard identification includes consideration during:

Planning, design, procurement, construction, hook-up, installation and commissioning;

Routine and non-routine operating conditions including shut-down, maintenance and start-up; Incident and potential emergency situations, including those arising from loss of containment,

material failures, structural failures, natural disasters, sabotage, breaches of security andhuman errors;

Decommissioning, abandonment, dismantling and disposal; and

Potential hazards and effects associated with past activities.

EOCP trains selected personnel from different sections of the organization on the specialized tools for hazard identification such as JSA, HAZIDs etc. The training is required since hazards and effectsidentification requires specialized technique and system, operational experience and technicalknowledge.

In hazards identification process, the type of hazards associated with either the activities or equipment

and their effects shall be identified. The screening criteria shall also be established in order to definethe acceptable and unacceptable level of risk.

Job Safety Analysis Procedure (PM-EOCP-CORP-HSE-510)

5.2 Risk AssessmentEvaluation of the risk posed by the identified hazards requires consideration of both the severity of theconsequences of a potential event and probability of its occurrence.

EOCP maintains a procedure to evaluate risks and effects from identified hazards against screeningcriteria, taking account of probabilities of occurrence and severity of consequences to people,

environment, facilities and business.

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 ALARP is the basis to be used when uncertainties arise from evaluation and agreed by all partiesinvolved.

Once the hazards and its effects have been identified and assessed, they shall be considered againstan HSEQ risk screening criteria. Screening criteria are values or standards against which the identifiedhazards or effect can be judged such as occupational exposure limits, gas emission limits, wastewater discharge limits and engineering standards.

In cases where the relevant HSEQ risk screening criteria is defined by local legislation or clientsstandards, such requirements shall be complied with. However, where EOCP HSEQ risk screeningcriteria is more stringent, the more stringent requirement shall be complied with.

For a qualitative risk assessment, the assessed risk can be regarded as either:

Low Risk - denoting risks low enough not to warrant further action or study;

ALARP Area - denoting risks which fall within the ALARP area. These will be considered for cost effective mitigation; and

High Risk - denoting risks that are so high that action to reduce them must be taken.

Events within the “High Risk” and “ALARP Area” categories of risk will be considered for further study.The EOCP Risk Assessment Matrix shall be used for the qualitative overview of risk and screeningcriteria in risk assessment carried out throughout EOCP operations. Figure 5.1 illustrates the EOCPRisk Assessment Matrix.

Hazard evaluations are recorded, together with the data sources and assumption used. These recordswhich are used by operation personnel in developing procedures and issuing work instructions,documented in any of the following documents:

Hazards and Effects Registers; and

Critical Operating Procedures.

5.3 Control and RecoverRisk reduction measures are taken to evaluate and implement appropriate measures to reduce or eliminate risks. Risk reduction measures include those to prevent or control incidents and to mitigateeffects. Mitigation measures include steps to prevent escalation of developing abnormal situations andto lessen adverse effects.

Risk reduction measures also include recovery preparedness measures which address emergencyprocedures as well as restoration and compensation procedures.

EOCP maintains procedures to:

Identify prevention and mitigation measures for particular activities, products and serviceswhich pose potential HSEQ risks;

Review activities to ensure that the measures proposed to reduce risks or enable relevantobjectives are met;

Implement, document and communicate to staff all interim and permanent risk reductionmeasures and monitor their effectiveness;

Develop relevant measures such as plans for emergency response to recover from incidentsand mitigate their effects;

Identify hazards arising from risk prevision and mitigation and recovery measures; and

Evaluate the tolerability of consequent risk and effects against the screening criteria.

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Figure 5.1: EOCP Risk Assessment Matrix

Consequences  Frequency of Occurrence

Severity Peo

ple

Ass

ets/

Productionloss

Enviro

nment

Reputation

Rare (1) Unlikely (2) Credible (5) Likely (8)Almost

Certain (10)

Rarely or

never heardof in E andP industry

Occurred

several timesin E and Pindustry

Incident hasoccurred inEOCP

Happen

several timesper year in

EOCP

Happens

several timesper year on aparticularlocation

None (0) No injury No loss or damage No effectNo

impact

Insignificant (1)Minor injury, First

aid

No disruption toproduction.

Loss/repair cost lessthan 10K USD

Slight effectLocal media

interest

LOWRISK 

Minor (2)Recordable case,

MTC, LTI

Possible disruptionto production.

Loss/repair cost lessthan 100K USD

Minor effectLocal TV,

national papers

Moderate (3)Multiple LTIs, one

PD

Productionshutdown.

Loss/repair cost lessthan 1M USD

Local effectConsiderable

impact

ALARPAREA 

Major (4) One fatality,multiple PDs

Major production

shutdown.Loss/repair cost lessthan 10M USD

Major effect

National TV,

internationalpapers

HIGHRISK

Critical (5)More than one

fatality

Loss of facility.Loss/repair cost

more than 10M USDMassive effect

InternationalTV, extended

coverage

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6. PLANNING AND PROCEDURES

6.1 HSEQ and Emergency PlanningThe Corporate HSEQ Plan is constructed in coordination with the aspiration of the company businessservices and EOCP Management Team guided by:

  Specific client’s standards on HSEQ;

Regulatory requirements;

International conventions;

Local community and authority expectations;

Company strategic objectives and targets; and

Weaknesses identified from operation and service units, Departmental/Project Managers andcorporate HSEQ-MS self-assessment questionnaire and annual HSEQ-MS reviews.

The Corporate HSEQ Plan is reviewed at the HSEQ Steering Committee and approved by the MD.

The Departmental/Project Managers cascade the corporate plan, with the assistance of their supervisors and use it as input to their respective HSEQ plans.

6.3.1 HSEQ Objectives and Targets

The Corporate HSEQ Plan drives the establishment of HSEQ Objectives and Targets at corporatelevel. At the lower level, Departmental/Project HSEQ Plan establishes HSEQ Objectives and Targetsfor each functional department/project. Each EOCP employee is required to establish personal HSEQobjectives and targets.

HSE Objectives and Targets Establishment Procedure (WP-EOCP-CORP-HSE-513)

6.3.2 HSEQ Management ProgramsThe Corporate HSEQ Plan establishes company-wide performance indicators and annual targets. Italso includes a list of action or management programs to be completed within set completion targetdates and by respective action parties. These management programs are developed in the respectiveoperation and service units to track progress against a target set to achieve continual improvement of the HSEQ performance of a given activity.

HSE Management Programs Establishment Procedure (WP-EOCP-CORP-HSE-514)

6.3.3 Emergency Preparedness and Crisis Management

EOCP ensure emergency preparedness through identification of foreseeable emergency situations by

HEMP and establishing Emergency Response Plan (ERP) which is periodically assessed for itseffectiveness.

EOCP emergency response tier is broken down into:

Departmental/Project/Facility level emergency response managed by the On-sceneCommander (OSC) with operationally ready Emergency Response Team (ERT);

Regional level emergency response managed by the Emergency Coordinator (EC) throughEmergency Command Centre (ECC); and

Corporate level crisis management led by Managing Director.

In general, emergency at operation/ project site must be handled directly by the operation and serviceunit management. EOCP Crisis Management Team (CMT) headed by the Managing Director will onlybe activated when the emergency condition escalates to a higher level requiring outside resources.

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The ERP is reviewed annually, led by the HSE Manager together with EC and OSC to identifyweaknesses and propose improvements. The findings of the system review are presented to theHSEQ Steering Committee. The ERP is simulated throughout the year by a series of table top and liveexercises followed by post mortems. Reports and reviews are recorded for documentation purpose.

Emergency Response Preparedness Procedure (PM-EOCP-CORP-HSE-515)

6.2 Document ControlFor all critical task and their supporting tasks, written procedure are developed and maintained atworkplace. The procedures are simple, understandable and accessible to all staff to ensure itseffectiveness. It is also important that the procedures include measures to control HSEQ risk andmeans for communicating the work instructions to the staff prior to job execution.

EOCP maintains HSEQ records which are made available to all clients and suppliers as needed todemonstrate HSEQ compliance and the effectiveness of the operation of the Management System.

The Departmental/Project Manager in liaison with the QA Manager will be responsible for co-ordinating the dissemination of any HSEQ records to clients and suppliers. HSEQ records must belegible and traceable to the product or activity they represent. HSEQ records retained on the projectsare normally outlined in the HSEQ Plan, QA/QC Plan, Inspection and Test Plan, contracts and/or project plans.

Measures are taken to prevent damage or deterioration to all records retained. Records are retainedfor a period of time in accordance with contract or statutory requirements, whichever is greater.

EOCP maintains procedures for controlling HSEQ-MS documents to ensure that:

They can be identified with the appropriate company, function or activity;

They are periodically reviewed, revised as necessary and approved for adequacy byauthorized personnel prior to issue;

Current versions are available on the EOCP website and all printed copies are uncontrolledand may be found at those locations where they are needed; and

When obsolete, they are promptly removed from all points of issue and points of use.

Documentations are legible, dated (with dates of revision), readily identifiable, numbered (with aversion number), maintained in an orderly manner and retained for a specified period.

Policies and responsibilities are established for the modification of documents and their availability toemployees, contractors, government agencies and the public.

 A complete hard copy set of signed and approved HSEQ-MS documentation are kept by the HSEQdepartment.

The EOCP HSEQ documentation is structured into 5 levels as shown in Figure 6.1 and Table 6.1.

Management System Documentation Numbering (BP-EOCP-CORP-QMS-502)Procedure Development, Issue and Change Control (PM-EOCP-CORP-QMS-541)

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Figure 6.1: EOCP HSEQ-MS Documentation Hierarchy

Note : The HSE-MS Documentation Hierarchy as illustrated above is deployed on projects andoperations in varying stages and is adapted as applicable depending on the work scope.

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Table 6.1: EOCP HSEQ-MS Documentation Hierarchy

Level I - PolicyStatements of corporate HSEQ policy that applyto all employees.

Level II Business Practices – e.g. HSEQ Manual

Describe the policy, organisation,responsibilities and arrangements of theappropriate management system in line with therecognised standard e.g. ISO 9001:2000, ISO

14001:2004 or OHSAS 18001:1999

Level III - Work Processes Linkage

Describe work process required which isdesigned to promote a common understandingamong interfacing departments, group or discipline that contribute to a given process. Itidentifies who does what and functionalresponsibilities of the individual departments.Figure 6.2 and 6.3 illustrates HSE and QualityLinkage of Processes respectively.

Level IV Process Maps/Procedures

Intent of this is to provide detail process toachieve goals. This is provided, for the ease of implementation, in the form of written narrative,Procedures or Process Maps or a combinationof both.

ST

END

 Level V - Work Methods and Instructions

Details of how tasks within a process areperformed. Normally deployed in a singlediscipline and relevant to a particular task.

C

 

HSEQ-MS

Manual

HSEQPolicy

Work

Instructions

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Note : The below describes the key activities performed by the HSE Function and associated procedures that support its successful implementation .

Audit &Review

Leadership &

Commitment

Policy &

Strategic

Objective

Organization,

Responsibilities

& Resources

Hazards &

Effects

Management

Planning &

Procedures

Implementation

& Monitoring

HSE LINKAGE OF PROCESSES

OperationalControl Procedures

Emergency Response PreparednessProcedure

Doc No: PM-EOCP-CORP-HSE-515

HSE Management Programs

Establishment ProcedureDoc No: WP-EOCP-CORP-HSE-514

HSE Objectives & Targets

Establishment Procedure

Doc No : WP-EOCP-CORP-HSE-513

HSE Performance Measurement, Monitoring &

Reporting Procedure

Doc No: WP-EOCP-CORP-HSE-529

Corrective & Preventive Action

Doc No: PM-EOCP-CORP-HSEQ-531

Hazards & Effects Management

Procedure

Doc No: PM-EOCP-CORP-HSE-509

Job Safety Analysis

ProcedureDoc No: PM-EOCP-CORP-

HSE-510

Risk Control Procedure

HSE Training & Competence Evaluation

Procedure

Doc No: PM-EOCP-CORP-HSE-507

Internal & External CommunicationProcedureDoc No: WP-EOCP-CORP-HSE-508

Legal & Other RequirementsIdentification Procedure,

Doc No: BP-EOCP-CORP-HSE-506

Management ReviewDoc No.: PM-EOCP-CORP-HSEQ-535

Internal & External Quality Audits

Doc No.: PM-EOCP-CORP-HSEQ-533

Incident Notification, Investigation & ReportingDoc No: PM-EOCP-CORP-HSE-532

PPE Management ProcedureDoc No: WP-EOCP-CORP-HSE-511

Occupational Health & Hygiene

Management ProcedureDoc No: WP-EOCP-CORP-HSE-512

Management of FacilityIntegrity ProcedureDoc No: WP-EOCP-CORP-

HSE-536

HSE Documentations & Records ProcedureDoc No: WP-EOCP-CORP-HSE-530

Emergency Equipment Management

Procedure

Doc No: WP-EOCP-CORP-HSE-516

Maintenance ManagementProcedureDoc No: WP-EOCP-CORP-HSE-517

Waste ManagementProcedureDoc No: WP-EOCP-CORP-HSE-518

Discharge Control

ProcedureDoc No: WP-EOCP-CORP-HSE-519

Emission ControlProcedure,Doc No: WP-EOCP-CORP-HSE-520

ResourcesConservationProcedureDoc No: WP-EOCP-CORP-HSE-521

Hazardous MaterialManagement ProcedureDoc No: WP-EOCP-CORP-HSE-522

Contractor HSE

Management ProcedureDoc No: WP-EOCP-CORP-HSE-528

Management of ChangeProcedureDoc No: PM-EOCP-CORP-HSE-525

Material Handling

ProcedureDoc No: WP-EOCP-CORP-HSE-523

Lock-out Tag-out(LOTO) ProcedureDoc No: PM-EOCP-CORP-HSE-527

Lifting ProcedureDoc No: PM-EOCP-CORP-HSE-537

Environmental Management Procedure

Doc No:WP-EOCP-CORP-HSE-536

HSE Site Inspection ProcedureDoc No.: WP-EOCP-CORP-HSE-534

Permit-to-Work

(PTW) ProcedureDoc No: PM-EOCP-CORP-HSE-526

 

Figure 6.2: EOCP HSE Linkage of Processes

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Note : The below describes the key activities performed by the Quality Function and associated procedures that support its successful implementation .

Planning

&

Re-sourcing

Check

& Review

Design

QUALITY LINKAGE OF PROCESSES

ManagementSystems

& ISO

Certification

Audit /Measurement /

Evaluation /Prevention &Continuous

Improvement

CustomerSatisfaction

Project Quality PlanningDoc No.: PM-EOCP-CORP-QMS-540

HR

Procedures

HSEQ Management System Manual

Doc No.: MAN-EOCP-CORP-HSEQ-501

Procedure Development, Issue &Change Control

Doc No.: PM-EOCP-CORP-QMS-541

Process Owners Business Practice

Doc No.: BP-EOCP-CORP-QMS-503

Management Review

Doc No: PM-EOCP-CORP-HSEQ-535

Corrective & Preventive Action

Doc No.: PM-EOCP-CORP-HSEQ-531

Internal & External Quality Audits

Doc No.: PM-EOCP-CORP-HSEQ-533

Customer FeedbackDoc No.: PM-EOCP-CORP-QMS-539

Lessons Learnt &

Knowledge CaptureDoc No.: PM-EOCP-CORP-QMS-505

Problem Resolution

Problem Resolution GuideDoc No: PM-EOCP-CORP-QMS-544

Control of Non-Conforming Product

Doc No.: PM-EOCP-CORP-QMS-543

Quality Assessment of SuppliersDoc No: PM-EOCP-CORP-QMS-542

Coordination of QualityResources

Doc No.: PM-EOCP-CORP-QMS-538

Internal & External Quality AuditsDoc No.: PM-EOCP-CORP-HSEQ-533

Corrective & Preventive ActionDoc No.: PM-EOCP-CORP-HSEQ-531

Management Review

Doc No.: PM-EOCP-CORP-HSEQ-535

Customer SatisfactionDoc No.: PM-EOCP-CORP-QMS-504

 

Figure 6.3: EOCP Quality Linkage of Processes

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6.3 Operation Control ProceduresControls for critical tasks are documented in the safety cases and HEMP registers and Process

Owners Business Practice. Operational control is essentially maintained through: Implementation of HSEQ manual and subsequent procedures in EOCP Business Processes;

Periodic review of HSEQ manual and subsequent procedures;

Periodic Training Needs Analysis and training;

Audits; and

Preventive, routine and emergency maintenance programmes.

Departmental/Project/Operation Managers have accountability over day-to-day operation,performance and development of all facilities. This accountability includes controlling the associatedHSEQ risks. EOCP personnel managing contractors are responsible for specifying appropriateprocedures and work instructions for contractor activities and for ensuring their adherence. Workinstructions are generally developed within departments. Therefore, it is the responsibility of individualDepartmental/Project Managers (Process Owners) to implement and communicate these documents

among their teams.

Process Owners Business Practice (BP-EOCP-CORP-QMS-503)

6.3.4 Engineering

The Engineering Core Process describes how the company plans and control the design anddevelopment of the product in accordance to the requirements of the contract. It encompasses thefollowing activities:

Review Design Basis and Criteria

Plan Design Work

Produce/Monitor Design

Control Design Change Check and Review Design

Design Verification

Design Validation

Approve Design

Deliver Design to Procurement and Construction

The Engineering Core Process is verified through application of EOCP’s Core Process Elements listed(but not limited to) below:

Identify all design input and deliverables

Establish schedule for deliverables

Implement design QC Plan

Management of change

Resolve design queries

Check document and conduct design review

Validate internal / external design equipment

Check output meets design basis

Obtain client approval for changes

Internal/external approval of design dossiers

Procurement, construction and operations review and validation

Establish equipment list and material take off 

The end results of the interrelated actions undertaken through-out the Engineering Core Process isthe actual design to be constructed or fabricated by the company in accordance to the requirement of the contract. In some instances the Engineering process is the final deliverable.

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6.3.5 Procurement

The Procurement Core Process describes how the company plans, selects and obtain defect-freeequipment, materials and services from its suppliers and subcontractors that satisfy its customer’srequirements. It encompasses the following activities:

Planning

Enquiry

Evaluation

Award

Order coordination

Release and Delivery

The Procurement Core Process is verified through application of EOCP’s Core Process Elementslisted (but not limited to) below:

Establish Procurement Plan including integrity assurance/performance measures

Obtain client approval on supplier listing Establish export compliance and requirements

Rationalise resource plan

Establish criticality strategy, as required

Package risk identification

Establish evaluation criteria

Review and conduct audits

Check purchase order package for completeness prior to issue

Package risk management

Review final documentation

Reconcile and close-out purchase orders

The end results of the interrelated actions undertaken throughout the Procurement Process is thesuccessful selection of the right supplier and/or subcontractor to provide the equipment, materials andservices to the company to complete the deliverable as required by the contract. In some instancesthe Procurement process is the final deliverable.

6.3.6 Construction Management

The Construction Management Core Process describes how the company manages a constructionproject from start to close out. It encompasses the following activities:

Project start-up

Mobilisation / demobilisation

Project planning

Project execution

Project close-out

The Construction Management Core Process is verified through application of EOCP processelements listed (but not limited to) below:

Establish construction management plan

Prepare project quality control plan which is linked to subcontract QC management plan

Prepare Inspection and Test Plan

Include integrity assurance/performance measure

Conduct gap analysis/pre-start audit (action plan)

Review/audit/approve subcontractor work processes

Monitor cost against budget and progress against schedule

Ensure change control is managed, reviewed and approved.

Review construction documents for completeness and ascertain punch list items Ensure customer property including intellectual property is protected and maintained

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Ensure mechanical completion close-out

Close out all Projects technical queries, change orders, variation orders, audits and correctiveaction requests

Prepare project close out report

Compile lessons learned

The end result of the interrelated actions undertaken throughout the construction management coreprocess is the successful management and completion of the project to the satisfaction of thecustomer. In some instances this process is the final deliverable.

6.3.7 Construction

The Construction Core process describes how the company construct or fabricate the productaccording to the requirements of the contract. It encompasses the following activities:

Receiving equipment/materials]

Prepare materials

Fabrication activities Mechanical completion

Pre-commissioning/commissioning

Verification and Validation

Load-out

The Construction core process is verified through application of EOCP’s core process elements listed(but not limited to) below:

Identification and ensure traceability of materials

Ensure compatibility of materials

Check and ensure qualification of personnel

Establish inspection requirements

Ensure control of welding consumables Ensure change control is managed, reviewed and approved

Check testing requirements

System completion checks

Ensure correct load out equipment

The end result of the interrelated actions undertaken throughout the construction process is thesuccessful completion of the deliverable to the requirements of the contract. In some instances, thisprocess is the final deliverable

The construction procedures are defined at the project stage and identified in the project plans.

6.3.8 InstallationThe installation core process describes the installation of the constructed or fabricated product asrequired by the contract. It encompasses the following activities:

Selection of vessels/tugs/barges

Mobilisation and demobilisation

Field installation

Tie-ins

The installation core process is verified through application of EOCP’s core process elements listed(but not limited to) below:

Establish required size and capacity

Ensure marine warranty surveyors approvals

Monitor and ensure that certification of personnel are valid Ensure incident and accident free installation

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Monitor progress against schedule

Minimise repairs and defects

Establish non-destructive testing and other inspection requirements

The end result of the interrelated actions undertaken throughout the installation process is thesuccessful installation of the constructed or fabricated product. In some instances this process is thefinal deliverable.

6.3.9 Hook-up and Commissioning

Hook-up and commissioning follows on from the close out of mechanical completion and involves pre-commissioning checklist conclusion and start-up. Completion is achieved when all agreeddeliverables, records, testing have been delivered to and accepted by the client.

Hook up and commissioning process are verified through the application of elements including but notlimited to:

Maintenance of job cards Maintenance of the commissioning management system

Completion of the commissioning procedure check-lists

6.3.10 Operations and Maintenance

Operations and Maintenance of plants and installations are supported through the use of suppliedoperating manuals approved by the client. Adequately experienced personnel with the right skills andknowledge will be deployed to operate and maintain the facilities.

Detailed performance standards will give the measurable values that the organisation requires to meetin order to achieve its goals. Strategies will be developed, planned, organised and implemented tomeet the standards and the performance will be monitored, reviewed and developed to givecontinuous improvement or reinforcement to the process.

6.3.11 Marine

The marine core process describes how the company deals with operation and maintenance of marinevessels. It encompasses the following activities:

Operation and Maintenance of Pipe Lay Barge; and

Operation and Maintenance of Floating Production Storage and Offloading facility.

The marine core process is verified through application of EOCP’s core process elements listed (butnot limited to) below:

Instruct the fleet and shore based staff on policies and procedures in compliance to the

International Safety Management (ISM) Code for Safety Operations of Ships and PollutionPrevention

Ensure marine warranty surveyors approvals

Monitor and ensure that certification of personnel are valid under international marine codes

Minimise and if possible eliminate pollution to marine environment

Monitor progress of projects and production activities against planned schedules

Minimise repairs and defects of marine vessels

6.3.12 Facility Integrity

Facility integrity and management of HSEQ risk are closely linked. Maintaining facility integrity is a

major control mechanism to manage many HSEQ risks i.e. loss of containment, structural failure, fireand explosion.

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EOCP maintains procedures to ensure that facilities or installations are suitable for the requiredpurpose and comply with relevant legislative requirements, industrial codes and internationalstandards throughout facilities life cycle i.e. design, procurement, construction, installation, operation

and maintenance phase.

Pre-procurement and pre-construction assessment of new facilities and equipment includes explicitassessment of appropriateness to meet HSEQ requirements and emphasizes design as the bestpreventive measure to reduce risk and adverse HSEQ effects.

EOCP procedures and systems for ensuring facility integrity address structural integrity, processcontainment, ignition control and systems for protection, detection, shutdown, emergency response,evacuation and life saving.

6.3.13 Management of Change

EOCP requirement for planning and controlling changes within its operations either temporarily or permanently, in people, plant, processes and procedures, is addressed in relevant changeprocedures. The procedures are suitable to address the HSEQ issues involved, according to thenature of the changes and their potential consequences. The procedures also address:

The changes and its implementation;

Government/local authority approval and reporting;

Responsibility for reviewing and approving the changes or its implementation;

Measures to identify hazards and to assess and reduce risks;

Hazards communication and training requirements;

Implementation timeline;

Verification and monitoring requirement; and

Acceptance criteria and action to be taken if breached.

Management of Change Procedure (PM-EOCP-CORP-HSE-525)

6.3.14 Permit-to-work System and LOTO

EOCP operations employ a Permit-to-Work System and LOTO program to ensure all work is carriedout safely in a controlled manner and that everyone is aware of the hazards involved in their work andof the precautions to be taken to ensure safe work.

Operational personnel are put through vigorous training and assessment to understand and implementarrangements set in the PTW/LOTO programs.

Permit-To-Work Procedure (WP-EOCP-CORP-HSE-526)

Lock-out Tag-out Procedure (WP-EOCP-CORP-HSE-527)Shipboard Operations, Section 7 Emas Offshore SMM

6.3.15 Contractor’s HSEQ Management

 A considerable part of EOCP activities may depend on contractors to carry out a wide variety of worksand the majority of these are carried out in and around workplaces of relatively high risk.

Especially for large and longer-term contracts, there is a need for early identification of clear andcommon HSEQ objectives from the onset and it is imperative to include these in the contract.

Contractors are required to develop HSEQ management system interface documents aligned tosatisfy EOCP HSEQ policies, manual, procedures and work instructions. All contractors’ activities,products and services must meet the local and international legislations pertaining to HSEQ andEOCP HSEQ-MS requirements.

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 All EOCP contractors are pre-qualified with a rating for HSEQ competency and performance. EOCPpersonnel in charge of contractors are responsible for assessing the possible risks of contracts beforeawarding and ensure that the contractor’s HSEQ plan is:

assessed for fitness prior to contract award; reviewed for compliance and fitness prior to mobilization;

monitored for compliance during the execution phase; and

reviewed during contract close out.

6.3.16 Environment Management

EOCP Corporate Environment Management Plan (EMP) is designed to meet ISO14001 EMS standardand EOCP Senior Management provides unwavering commitment and support towards achieving theTarget Zero goal of “Zero Damage to Environment. 

The EMP identifies and plans on operations that are associated with or may have identified

environmental impacts consistent with its HSEQ Policy, Objectives and Targets, in order to ensure thatthey are carried out under specified conditions, by:

establishing, implementing and maintaining documented procedures to control situationswhere their absence could lead to deviation from the HSEQ Policy, Objectives and Targets;

stipulating the operating criteria in the procedures; and

establishing, implementing and maintaining procedures related to the identified environmentalimpacts of goods and services used by the organization and communicating applicableprocedures and requirements to suppliers, including contractors.

Environmental Management Procedure (WP-EOCP-CORP-HSE-536)

7. IMPLEMENTATION AND MONITORING

7.1 Responsibility and OwnershipFull implementation of the HSEQ-MS means that people are doing what the Management Systemsays they should be doing, at all levels of the organization. Successful implementation requiresembedding HSEQ into the EOCP culture; with clear responsibilities and Departmental/Projectownership.

 Activities and tasks are conducted according to procedures and work instructions developed inaccordance with HSEQ policies and set objectives and targets:

At management level, activities will normally take the form of plans and actual implementation;and

At departmental/project level, activities shall be in the form of executing activities and tasksassigned.

Successful implementation of EOCP HSEQ-MS requires that it be viewed as part of the way EOCP dothings. HSEQ management is an integral part of our business.

Responsibility for conducting critical tasks is clearly communicated to the individuals involved. Eachresponsible person monitors and regularly reports the performance of the critical activities using setperformance indicators.

People identified as responsible for critical tasks must take ownership. To achieve this, it is essentialfor Project staff to be genuinely involved in developing the HSEQ-MS, HSEQ Plans and OperationalSafety Cases.

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7.2 Performance Indicators and MeasurementEOCP establishes procedures to maintain appropriate records to demonstrate conformance to theHSEQ-MS, policies, objectives and targets, local legislations, international standards and client’s

specific requirements.

EOCP regularly measures, records, tracks and reports HSEQ performance against objectives andtargets set in the HSEQ plan and in maintaining control of critical activities.

EOCP develops procedures for periodic review of performance against annual Corporate andDepartmental/Project HSEQ Plans.

EOCP HSEQ performance measures are generally of two types:

Proactive systems, which monitor achievements of plans and the extent of compliance withlegislations, standards and procedures; and

Reactive systems, which monitor incidents and emissions.

Proactive monitoring provides information in the absence of any incidents, health impairment, damageto the receiving environment or breach of laws. Proactive performance indicators are forward lookingand predictive, aimed at raising the awareness of the possibility of incidents that might happen.

Reactive monitoring provides information on incidents that have occurred and provides insights intomeans of preventing similar incidents in the future. Reactive performance indicators provide evidenceof deficient HSEQ performance.

HSE Performance Measurement, Monitoring and Reporting Procedure (WP-EOCP-CORP-HSE-529)

7.3 Monitoring Program A monitoring program is required to measure HSEQ performance and the implementation of theHSEQ-MS, against established targets. A monitoring program:

Identifies the information to be obtained;

Defines the required accuracy of the results;

Specifies the monitoring methods and identify monitoring locations;

Specifies the frequency of measurement; and

Defines roles and responsibilities for monitoring.

 A monitoring program also regularly examines progress towards achieving set departmental/projectlevel HSEQ Objectives and Targets.

7.4 Data Accuracy and CalibrationSufficient quality control over measurement errors is important to ensure clear and accurateinterpretation of monitoring results and to maintain consistency of measurement.

Monitoring equipment is calibrated by competent personnel on regular basis.

Procedures are established for collection, analysis and interpretation of monitoring data.

7.5 RecordsEOCP establishes a system for records management in order to demonstrate the extent of compliancewith legislative requirements, HSEQ policies and its requirements and to record the extent to which

planned objectives and performance indicators which has been met.

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The retention times of records are captured, recorded and analyzed, such that evidence is available of the achieved compliance levels, to identify problem areas, to ensure the effectiveness of actualimplementation and its traceability.

HSE Documentations and Records Procedure (WP-EOCP-CORP-HSE-530)

7.6 Incident Investigation and ReportingEOCP maintains procedures for incident investigation, notification and reporting for any incidentoccurred in the company. Any accident or near miss must be notified, analyzed, reported and followedup with corrective and preventive measures to prevent recurrence

Incidents may affect people or the environment, or the assets and reputation of EOCP.

The corresponding consequences of incidents are:

Personal injury/occupational illness;

Facility loss/damage; Environmental damage/impacts; and

Business reputation affected.

EOCP defines requirement relating to the investigation and reporting of incident including near missesthat may arise and in the course of EOCP business activities.

The purpose of incident investigation and reporting are to ensure that:

All cause of incident are identified;

Lesson learnt from incidents are identified and implemented, in view of preventing recurrence;

All relevant parties within EOCP are promptly notified; and

Any legal issues relating to the incident are duly considered.

 All incidents including near misses, that arise within EOCP activities are investigated and reported inaccordance with EOCP corporate procedures and Client reporting standards as applicable..

 All incidents are reported immediately to appropriate supervisors and responsible manager, who willthen take the required actions including participating in incident investigation, reporting andimplementation of corrective actions and preventive measures.

For contractors, they need to notify all incidents to the respective EOCP contract in-charge and ProjectHSEQ personnel.

The Project HSEQ personnel must notify the Client within 24 hours. Notification to the authorityconcerned will be managed by the EOCP HSEQ Manager or his designate in project organization.

Lesson-learnt from incidents are disseminated as widely as possible during daily tool box meeting(TBM) and HSEQ Alerts; in particular where lesson-learnt from the incident has lateral applications tothe EOCP businesses as well as activities conducted by the clients. The HSEQ alerts are distributedinternally as well as to the clients’ office, business partners and other stakeholders. 

 Any major incident such as fatality, lost time injury (LTI), major spillage, occupational illnesses and noncompliance to legislative requirements shall be reported directly to EOCP Senior Management inaccordance with the company’s Emergency Response Plan.

Incident Notification, Investigation and Reporting Procedure (WP-EOCP-CORP-HSE-532)

7.7 Corrective and Preventive Action

When non-conforming materials or non-compliant processes are detected, all associated and rootcauses will be investigated. A corrective action is selected in balance with associated risks. Corrective

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actions shall be documented and evaluated for effectiveness and, if necessary changes made toprocedures and work practices to prevent recurrence.

Preventive action is directed toward eliminating the causes of potential non-conformances. It shall be

to a degree appropriate to the magnitude of problems encountered. Non-conformance/observationsraised as a result of Management System reviews and audits will be reviewed by the management for preventive action, where applicable.

EOCP defines the requirement in term of responsibility and authority for initiating investigation andcorrective action in the event of non compliance with specified requirements relating to HSEQ-MS.

Situation of non- compliance may be identified by the monitoring programs, through communicationsfrom employees, contractors, customers, government agencies or the public or from investigations of incidents.

For any sign of non-compliance to HSEQ-MS, associated with procedures and legislativerequirements, the responsible manager in association with HSEQ Corporate will initiate an

investigation with an intention to establish the causes of non compliance and develop relevantmitigation measures.

The party responsible must ensure the followings are executed in the event of any HSEQ noncompliance:

Notify relevant parties;

Determine the root cause of non compliance;

Initiate the necessary investigation;

Provide corrective action with consultation of HSEQ committee;

Ensure the preventive action are in place for long term measures;

If necessary, revise procedures to incorporate actions to prevent recurrence; and

Communicate the non compliance to all staff and contractors as a lesson learnt.

Progress in implementation of corrective and preventive action are monitored and presented at EOCPHSEQ Steering Committee Meeting.

Corrective and Prevention Action (PM-EOCP-CORP-HSEQ-531)

7.8 Non-ConformanceNon-conformance may be sudden and temporary, or they may persist for long periods. They mayresult from deficiencies or failures in the HSEQ-MS itself, failures in plant or equipment or from humanerror.

Quality Manager or his delegate will be responsible for the control of non-conforming materials and/or processes. This will include the identification, documentation, evaluation, segregation, disposition andpreventing the use of non-conforming materials and/or processes. Quality Manager or his delegate willalso be responsible for the notification of affected departments when non-conforming materials and/or processes are detected.

Non-conformance is reported when there is a deviation from the agreed system, procedure or specified requirements that affect the safety, quality or continuity of the operation. Quality Departmentperforms trend analysis as required and decided by the HSEQ Steering Committee duringManagement Review.

Investigating non-conformance should fully establish the causes, including failures in the HSEQ-MS.Investigations enable the planning of corrective action including measures for:

Restoring compliance as quickly as possible;

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Time scale to resolve;

Identification of root causes;

Appropriate corrective action for the immediate situation;

Preventing any recurrence;

Evaluating and mitigating any adverse HSEQ effects;

Ensuring satisfactory interaction with other components of the management system; and

Evaluation of the completeness and effectiveness of the solution and follow-up to ensure thatthe problem does not recurring.

Implementing corrective action will not be complete until the effectiveness of the above measures hasbeen demonstrated. This includes making the appropriate changes to EOCP procedures and records.

Control of Non-Conforming Product (PM-EOCP-CORP-QMS-543)

8 AUDIT

8.1 Audit Plan, Process and Hierarchy

EOCP believes that audits are essential for improvement and reaching the company’s objectives. Thisis achieved by a combination of periodic assessment and/or audit of projects and businessmanagement and support activities.

Internal audits are carried out with a minimum frequency of once a year and/or as required by thecontract. External Audits are conducted as required on a project or bid normally on a vendor or asubcontractor’s facility. 

 Auditing addresses the periodic assessment of system performance, its effectiveness and inherent

suitability against the business requirement. EOCP defines the requirements in respect of internalHSEQ-MS auditing, to provide assurance to management that:

HSEQ management within the EOCP conforms to HSEQ-MS;

The planning and implementation of activities within the EOCP is consistent with achieving theintents of EOCP HSEQ policies, strategic objectives, targets and plans; and

The level of understanding and implementation of the stipulated HSEQ requirements and theextent, to which they are adhered to in the Company, is appropriate and effective.

Audit PlanEOCP maintains an audit plan, dealing with the following:

Specific activities and areas to be audited. Audits will cover the operation of the HSEQ-MSand the extent of its integration into project activities and specifically address the elements of the HSEQ-MS;

Frequency of auditing for specific activities/areas. Audits will be scheduled on the basis of thecontribution or potential contribution of the activity concerned to HSEQ performance and theresult of previous audits; and

Responsibilities for auditing specific activities/areas.

Audit ProcessEOCP maintain procedures for audits to be carried out, as a normal part of business control, in order to determine:

Whether or not HSEQ-MS elements and activities conform to planned arrangements and areimplemented effectively;

The effective functioning of HSEQ-MS in fulfilling the company’s HSEQ Policy, Objectives and

performance criteria; Compliance with relevant local and international legislative requirements pertaining to HSEQ;

and

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Identification of areas for improvement, leading to progressively better HSEQ management.

EOCP establishes the audit protocols that covered the following as a minimum;

Allocation of resources to the auditing process;

Methodologies for conducting and documenting the audits, which may involve the use of questionnaires, checklists, interviews, measurements and direct observations, depending onthe nature of the function being audited.

Procedures for reporting audit findings in a controlled manner to those responsible for theactivity/area audited, who should take timely action on reported corrective actions andopportunities for improvement reporting should address:

o conformity or non-conformity of the HSEQ-MS elements with specified requirements;

o effectiveness of the implemented HSEQ-MS in enabling objectives and performancecriteria to be met;

o implementation and effectiveness of corrective actions from previous audits; and

o conclusion and recommendations.

System for auditing and tracking implementation status of audit recommendations; and

Distribution and control of audit reports.

The HSEQ audits are carried out internally by personnel from within the company but independent of the part being audited. However EOCP may also choose to engage external auditors where and whendeemed necessary. The audit and review are carried out on quarterly basis and shall be initiated bythe Operation Manager. The audit team are selected by the Operation Manager whom will ensure thataudit team members possess broad knowledge on HSEQ matters and are experience in auditingpractices and disciplines.

The audit team gathers information by observation, through interviews and by checkingdocumentations and hardware. The principal documents to be reviewed during the exercise includethe following:

HSEQ manual and procedures;

Incident Reporting files; Permit-to-work and execution of critical activities;

Medical log book;

Inspection records;

Equipment and machineries;

Adherence to HSEQ policies and objectives;

Adherence to procedures and work instructions; and

HSEQ statistics and performance.

Audit HierarchyEOCP operates a multi-tiered system for HSEQ audit type comprising:

Tier 1: Corporate HSEQ Audits led by HSEQ Specialists as appointed by the EOCP Senior Management. Audit findings are reported to the responsible managers of the auditeddepartmental/project, copied to the MD and the HSEQ Steering Committees;

Tier 2: Internal HSEQ Audits  led and conducted by a departmental/project HSEQ audit teamas appointed by departmental/project management. Audit findings are reported toDepartmental/Project Managers. Procedures on how to conduct audits are provided by theHSEQ Manager;

Tier 3: Contractor’s HSEQ Audits led and conducted by EOCP HSEQ Specialists as appointedby EOCP Senior Management. Audit findings are reported to Operations Director andcontractor ’s Senior Management. Procedures on how to conduct these audits are provided bythe HSEQ Manager; and

Tier 4: HSEQ Site Inspection conducted by Operation Manager, HSEQ Department andDiscipline Supervisors.

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8.2 Audit Team and Frequency

Audit TeamPeople conducting HSEQ audits are appropriately trained to be able to carry out the task objectively,impartially and effectively.

 Audit team members are selected so that their skills and knowledge are appropriate to the audit typeand scope. The audit team must have:

A broad knowledge of HSEQ matters;

Attended HSEQ Auditing training;

Adequate independence from the activities being audited, to enable objectives and impartial judgment;

Operational experience in the area being audited;

The necessary expertise and experience in auditing practices and disciplines;

Specialist HSEQ or other technical expertise or support, if necessary, from a wider range of specialists; and

The support and authority from management to procure the necessary information.

In order to maintain independence and objectivity, the Audit Team Leader and the majority of the auditteam will not have a direct reporting line to the Principal Auditee.

Audit Frequency All business processes are periodically audited, with the frequency and depth of HSEQ auditing beingdetermined based on:

The level of risk for the activity;

How critical the process or activity is, in relation to EOCP business objectives; The contribution or potential contribution of the activity concerned to EOCP overall HSEQ

performance; and

The results of previous audits.

 All business processes activities and facilities must be audited within a year.

Internal and External Quality Audits (PM-EOCP-CORP-HSEQ-533)

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9 REVIEW At periodic intervals the effectiveness of the Management System will be reviewed by the HSEQ

Steering Committee which comprises of the EOCP HSE Manager, Quality Manager, OperationsDirector, and representatives from the various departments as required. As a minimum, managementreview meetings will be conducted once a year.

9.1 Scope of ReviewThe content of review includes the EOCP and its activities focusing on HSEQ-MS and criticalactivities. The scope of management review specifically, but not limited, addresses:

To ensure Business Objectives are met;

To assess the effectiveness of the HSEQ Management System;

To review working practices within the company with a view to standardization and to identityall possible changes to improve working practices;

To review the results of Management System reviews, audits, non-conformances, corrective

and preventive actions and the effectiveness of these actions through trend analysis; To review customer feedback and complaints;

To review all continuous improvement initiatives;

Review of HSEQ policies for its applicability and continuing suitability due to emerging HSEQconcerns in specific areas e.g. potential regulatory developments, concerns of employees,contractors, customers, government agencies and the public market pressures which affectssensitivity of the environment;

Possible need for changes to the HSEQ plans, objectives and targets, in the light of changingcircumstances and the commitment to strive for continual improvement;

Review performance against targets;

Consequent amendments to the HSEQ-MS documentations;

Implementation of any recommendation made in audit reports;

Implementation of any recommendations made in investigating incidents;

Extent of follow-up on audit and incident action items; and

Resource allocation to achieve HSEQ objectives and for overall HSEQ-MS implementationand maintenance.

The review process is documented and its result recorded, to facilitate implementation of consequentchanges.Reviews are used to reinforce continual improvement of HSEQ-MS.

9.2 Responsibility for ReviewReviews are carried out by EOCP Senior Management consists of the following:

Managing Director (MD) as Chairman of the review;

Associate and Operations Directors;

Financial Controller;

Operation and Maintenance Manager;

HSE or QA/QC Manager as Secretary of the review; and

Functional/Departmental/Project Managers.

The minutes of the review meetings are held by the HSE or QA/QC Manager whom ensures thattimely follow-up meetings are arranged to review progress. No item is closed until the approved actionplans for improvement has been completed and found to be satisfactory. Minutes of the reviewmeetings are distributed to the relevant managers and to contractors for dissemination at their management meetings.

Management Review (PM-EOCP-CORP-HSEQ-535)

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ATTACHMENTS

ATTACHMENT A Consistency between ISO and ISM Codes with 

EOCP HSEQ-MS 

ATTACHMENT B Organisation Structure 

ATTACHMENT C HSEQ Roles and Responsibilities 

ATTACHMENT D List of Process Maps and Procedures 

ATTACHMENT E HSEQ Records Master List 

ATTACHMENT F Distribution List and Revision History